Justia Idaho Supreme Court Opinion Summaries

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This case arose from an Idaho Industrial Commission determination denying an application for unemployment benefits. William Wittkopf appealed pro se the Commission’s determination that he was ineligible for unemployment benefits because he voluntarily quit his job without good cause and he willfully made a false statement or willfully failed to report a material fact in his unemployment application. On appeal, Wittkopf challenged the factual findings made by the Commission and argued it violated his right to due process by taking into consideration the fact that he voluntarily terminated his employment approximately two and a half years prior to applying for unemployment benefits. After review, the Idaho Supreme Court concluded: (1) Wittkopf failed to provide a cogent argument on appeal regarding whether his right to due process was violated; (2) the Commission’s determination that Wittkopf voluntarily terminated his employment at Stewart’s Firefighter without good cause and without exhausting all reasonable alternatives was supported by substantial and competent evidence; and (3) the Commission’s determination that Wittkopf willfully made a false statement or willfully failed to report a material fact in order to obtain benefits was supported by substantial and competent evidence. Accordingly, the Commission’s decision and order denying Wittkopf’s application for unemployment benefits was affirmed. View "Wittkopf v. Stewart's Firefighter Food Catering, Inc." on Justia Law

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In this appeal, the Idaho Supreme Court was asked to clarify the meaning and extent of a defendant’s Sixth Amendment right to conflict-free counsel. Appellant Alfredo Alvarado argued his rights were violated because his public defender had previously represented a witness who was adverse to him on a felony charge. After disclosing the conflict, Alvarado’s attorney agreed that he and the public defender’s office would decline any future representation of the witness. However, Alvarado argued that counsel continued to have an actual conflict of interest because his ongoing ethical duties to the witness and former client prevented him from effectively cross- examining the witness. Alvarado contended this resulted in a structural defect in the trial, which necessitated overturning his convictions. In the alternative, Alvarado argued his unified aggregate sentence of twenty years to life for attempted strangulation and domestic abuse was excessive. After review, the Supreme Court determined Alvarado failed to show his counsel's representation constituted a fundamental error. He neither demonstrated an error affected the outcome of the trial, nor shown that a structural error denied him the right to counsel during a critical stage of the proceeding. Therefore, the Court ruled Alvarado was not deprived of his Sixth Amendment right to conflict-free counsel. The Court also held the district court did not abuse its discretion in sentencing Alvarado to a twenty-year to life aggregate sentence on his two felony convictions. View "Idaho v. Alvarado" on Justia Law

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Defendant Max Gorringe appeaeled a district court’s order amending of a no contact order. A no contact order was originally entered against Gorringe after he was initially charged with attempted strangulation in 2011. Upon acceptance of Gorringe’s guilty plea to that charge in 2012, the district court rescinded the existing no contact order and in its place included no contact provisions in the Judgment and Commitment. In 2018, Gorringe was charged with a misdemeanor for allegedly violating the no contact provisions contained in the original Judgment and Commitment. Gorringe sought clarification of the existing provisions originally entered the judgment, then moved to modify the no contact provisions. The parties stipulated to an amendment of the order in exchange for the dismissal of Gorringe’s misdemeanor charge. Although the district court expressed reservations regarding its jurisdiction to amend the no contact provisions that had been incorporated into the prior Judgment and Commitment, the district court nonetheless amended the 2012 no contact order based on the parties’ stipulation and the State’s assurance that the victim did not object to the amendment. Gorringe appealed the district court’s order amending the no contact provisions, asserting that the no contact provisions included in the 2012 Judgment and Commitment were invalid. Gorringe also claimed the district court lacked subject matter jurisdiction to amend the order in 2018. The Idaho Supreme Court concluded the no contact provision in the district court's 2012 Judgment was unenforceable; the court lacked jurisdiction to amend the 2012 no contact order. The district court order amending the no contact order was thus reversed, and the provisions in the 2012 sentencing order were void. View "Idaho v. Gorringe" on Justia Law

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At issue in this appeal was whether claimant Curtis Stanley filed a timely complaint against the Industrial Special Indemnity Fund ("ISIF") when Stanley filed his complaint more than five years after his industrial accident and more than one year after receiving his last payment of income benefits. The Idaho Industrial Commission (“Commission”) held it did not have continuing jurisdiction to entertain Stanley’s complaint against ISIF for non-medical benefits. The Commission found Idaho Code section 72-706 barred Stanley’s complaint and dismissed it. Stanley appealed, arguing continuing jurisdiction over medical benefits alone was sufficient to confer jurisdiction over complaints against ISIF and that the Commission erred in determining section 72-706 barred his complaint. Finding the Commission erred in determining section 72-706 barred Stanley's complaint, the Idaho Supreme Court reversed the Commission’s decision. View "Stanley v. Idaho Industrial Special Indemnity Fund" on Justia Law

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The State charged Carli Campbell as an accessory to a felony under Idaho Code section 18-205(1) for withholding or concealing information from police officers about an aggravated battery and burglary that occurred in her home in December 2017. After the evidentiary phase of the trial was completed, Campbell requested the district court instruct the jury that the State was required to prove that the alleged assailant, Michael Cross, committed the aggravated battery or burglary beyond a reasonable doubt. The State opposed this request and the district court agreed, concluding that while the State was required to prove Campbell had knowledge of the conduct that constituted an aggravated battery or a burglary, it was not was required to prove Cross committed the aggravated battery or burglary beyond a reasonable doubt. At the conclusion of the trial, the jury found Campbell guilty. Campbell now appeals her conviction to this Court. Finding no reversible error in the district court's decision, the Idaho Supreme Court affirmed. View "Idaho v. Campbell" on Justia Law

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Holly Cook appealed an administrative order entered by an Administrative District Judge (“ADJ”) declaring her to be a vexatious litigant pursuant to Idaho Court Administrative Rule 59. The order prohibited Cook from filing any new litigation pro se in Idaho without first obtaining leave of the court where the litigation was proposed to be filed. Ms. Cook petitioned for a divorce from her husband (“Mr. Cook”) in 2015. During the lengthy and contentious divorce proceedings, Ms. Cook had assistance of counsel for portions of the proceedings, but represented herself pro se when she did not. Some aspects of the divorce proceedings were appealed to the district court. Mr. Cook filed a moved that Ms. Cook declared a vexatious litigant. Neither party requested a hearing on Mr. Cook’s motion. The district judge presiding over the appeal referred the matter to the ADJ. The ADJ found that Ms. Cook largely failed to appear at dates set in scheduling orders that she (with and without counsel) agreed to. She failed at obtaining continuances, at having the trial judge disqualified, and to move the court for reconsideration of many intermediate decisions. She attempted to collaterally attack the default judgment of divorce, and at some point, was held in contempt for failing to respond to court orders during the divorce proceedings. Separate from the divorce proceedings, the ADJ noted Ms. Cook had filed nine pro se civil protection orders, all of which had been dismissed in favor of the parties from whom she sought protection. The Idaho Supreme Court determined the ADJ abused its discretion in declaring Ms. Cook a vexatious litigant; the ADJ did not review the merits and reason for dismissal in the nine civil protection actions, causing the ADJ to conclude incorrectly the final determinations were adverse to her. Furthermore, with respect to the divorce proceedings, the Court determined the ADJ abused its discretion by failing to make factual findings that Ms. Cook repeatedly attempted to relitigate issues already finally decided by the magistrate court. The Supreme Court concluded the ADJ did not make sufficient findings to support the conclusion that Ms. Cook’s filings were frivolous, unmeritorious, or filed with the intent to cause unnecessary delay. Accordingly, the Court reversed the prefiling order and remanded to allow the ADJ the opportunity to reconsider this matter. View "Cook v. Wiebe" on Justia Law

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Choice Feed, Inc. sued Ray and Susan Montierth, alleging that Ray breached an oral agreement to sell his feedlot property to Choice Feed once he arranged a 1031 tax deferred agreement. Although Ray collected money from Choice Feed that was to go toward the purchase of the feedlot property, he never arranged the 1031 exchange. Instead, without notice to Choice Feed, Ray sold the feedlot property to someone else while continuing to accept monthly payments from Choice Feed. At the conclusion of the trial, the jury found in favor of Choice Feed on one count of fraud against Ray, awarded compensatory damages, and assessed $250,000 in punitive damages. Ray moved for judgment notwithstanding the verdict, which the district court granted in part, thereby reducing the jury’s awards of both the compensatory and punitive damages. Ray appealed the jury’s verdict, including the compensatory and punitive damages that were reduced by the district court. Choice Feed cross-appealed the district court’s decision granting Ray’s motion for judgment notwithstanding the verdict and the resulting reduction in damages. After its review, the Idaho Supreme Court affirmed the district court on all issues raised in Ray’s direct appeal: (1) to deny Ray’s motion to dismiss for Choice Feed’s failure to plead fraud with particularity; (2) to give jury instructions that conformed with the evidence presented at trial; (3) to allow Choice Feed to seek improvement expenses as damages at trial; (4) to allow the jury to consider punitive damages; and, (5) to consider punitive damages in its prevailing party analysis and its conclusion that Choice Feed was the prevailing party. The Supreme Court also rejected Ray’s argument that Choice Feed did not have standing to bring suit or that it was not the real party in interest and the Court declined to add a tenth element of a transfer or sale of property to common law fraud. On Choice Feed’s cross-appeal, the Supreme Court reversed the district court’s decision to grant Ray’s JNOV motion and reduce the compensatory damage and punitive damage awards as raised in Choice Feed’s cross-appeal. However, the Court affirmed the district court on Choice Feed’s remaining issue raised in its cross-appeal concerning the award of prejudgment interest to Ray on his open account hay claim. Costs and attorney fees are awarded to Choice Feed as the overall prevailing party on appeal. View "Choice Feed Inc. v. Montierth" on Justia Law

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Lester McMillan bought a dilapidated house that Terry Asher and Pamela Kitchens (“the Ashers”) planned to repair. The parties orally agreed that the Ashers would perform certain repairs to make the house livable, rent the house from McMillan for five years, and then buy the house from McMillan. For reasons that were disputed, the sale was never consummated. However, the Ashers continued to live in the house, make improvements to the property, and pay monthly rent to McMillan. After relations between the parties soured, McMillan sued to evict the Ashers. The Ashers then sued McMillan for specific performance of the oral contract to convey or, in the alternative, restitution for the value of the improvements. The district court found the oral contract was unenforceable, but awarded the Ashers restitution for certain improvements. McMillan appealed, alleging the district court erred in determining that he was unjustly enriched and in determining the amount of restitution. The Idaho Supreme Court found the district court did not err, except for a minor miscalculation of the amount of restitution. View "Asher v. McMillan" on Justia Law

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In 1985, Gerald Pizzuto Jr. murdered Berta and Delbert Herndon. Pizzuto was convicted of two counts of murder in the first degree, two counts of felony murder, one count of robbery, and one count of grand theft. He was sentenced to death for the murders. Between 1986 and 2003, Pizzuto filed five petitions for post-conviction relief. His fifth petition for post-conviction relief was predicated on the holding in Atkins v. Virginia, 536 U.S. 304 (2002), in which the U.S. Supreme Court held that the execution of an intellectually disabled person constituted cruel and unusual punishment in violation of the Eighth Amendment to the United States Constitution. In his fifth petition, Pizzuto asserted that his death sentence should be “reversed and vacated” because he was intellectually disabled. The district court summarily dismissed Pizzuto’s petition. The Idaho Supreme Court held that the district court did not err when it dismissed Pizzuto’s fifth petition for post-conviction relief on the basis that Pizzuto had failed to raise a genuine issue of material fact supporting his claim that he was intellectually disabled at the time of the murders and prior to his eighteenth birthday. Pizzuto pursued this same claim in a federal habeas corpus action. In 2016, the U.S. District Court for the District of Idaho denied Pizzuto’s successive petition for writ of habeas corpus after holding a four-day evidentiary hearing in 2010. Although it affirmed the federal district court’s decision denying Pizzuto’s successive petition for writ of habeas corpus, the Ninth Circuit stated in dicta that its decision does not preclude Idaho courts from reconsidering whether Pizzuto was intellectually disabled at the time of the murders. Based on this dicta, Pizzuto filed a motion with the district court to alter or amend the judgment dismissing his fifth petition for post-conviction relief in accordance with Idaho Rule of Civil Procedure 60(b)(6). The district court denied Pizzuto’s Motion in early 2020. Because the district court did not abuse its discretion in denying Pizzuto’s Motion, the Idaho Supreme Court affirmed the district court’s decision. View "Pizzuto v. Idaho" on Justia Law

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Daniel Chernobieff appealed a district court’s decision on intermediate appeal to uphold a magistrate court’s summary dismissal of his petition for post-conviction relief. Chernobieff was convicted of a misdemeanor for driving under the influence with an excessive blood alcohol content in June 2014. After the Idaho Supreme Court upheld his conviction on direct appeal, Chernobieff filed a petition for post-conviction relief on the basis of ineffective assistance of counsel. He alleged that his defense counsel’s decision to object to testimony at a suppression hearing suggesting that the on-call magistrate could not be reached to obtain a warrant because his cell phone ringer was off was unreasonable and prejudicial. He argued that the objection to the ringer testimony prevented him from arguing at trial that the State did not have good cause for the on-call magistrate's unavailability. The magistrate court granted the State's motion for summary dismissal, reasoning the objection was an unreviewable strategic decision and would not have changed the outcome of the case. The district court, sitting in an appellate capacity, affirmed. Finding no reversible error, the Supreme Court also affirmed. View "Chernobieff v. Idaho" on Justia Law